VER. January 1, 2018 ACICS INITIAL GRANT OR RENEWAL OF ACCREDITATION REPORT Page 17 of 18

CRITERIA

3- 1-203. Data fotegrity. All da1a reported to ACICS for any purpo se is expected to reflect an accura te and verifiable pottrayal of institutiona l perfom1ance and is subject to review for integrity, accuracy, and completeness.

See also Appe ndix L

3-1-440- Student Services

3-1-441. Counseling and G11ida11ce. Each institution shall designate at least one person on staff exper ienced in counseling students on personal or academ ic problems and employment oppor1unities. The extent of such activity, and the personnel assigned to it, shall be determined by the size, classi fication, and admiss ions standards of the institution , the characte ristics and location of student s, and the means of communi cation with them. Orientation activities shall assist new student s in adapting to the inst itution. The follow ing are min imum expectat ions:

(a) A system of educational, occupationa l, and personal advising shall be availab le 10 students and shall be provided on a petiodic basis to ability-to-bene fit students enrolled pursuant to Section 3- l -303(b).

(b) Institutions shall emphasize retent ion and program completion for all students through activities that take into account their academic and socioeconomic charac teristics .

(c) Institution s shall provide emplo yment assistance and document activity. An inst itution shall not guarantee employment or the starting salary of its graduat es. Follow-up studies on graduates and employer satisfaction shall be conducted by all institution s at specific measuring points following placemen! of the gradu ate. All instit utions that use placemen t percentages or salary projections as part of their recruiting act ivities shall maintain data on all graduat es, includ ing the percen tage rece iving jobs and the percentage receiving jobs in the career fie ld for wh ich they we re trained . Instilution s also should keep data on students who do not graduate but who become employed on their own or with the institution' s assis tance.

An ins1i1u1ion is encouraged to prov ide placeme nt assistance, when requested , to grad uates of other ACICS -accredited institutions who are relocating to a new communi ty.

QUESTIONS

If Yes, is the size of the discount based on the financial benefit that the campus receives from the payment of cash earlier than would be required under the normal tuition payment schedule? 0 Yes O No O Not App licable

If No, insert the section number in parenthe ses and ex~ n:

4.53 Was the team able to verify the retention rate for the campus and for each program as reported on the Campus Accountab ility Report (CAR) last submitted to the Council? 0 Yes O No O Not Applicab le

If No, insert "Sec tion 3-1-203 and Append ix L" in parentheses and explain:

4.54 Was the team able to verify the graduates reported as unavailable for placement on the campus's most recent CAR?

4.55

D Yes D No D Not Applicab le

If No, insert "Sec tion 3-1-203 and Append ix L" in Qarentheses and explain:

Describe the proce ss by which students who receive financial aid are counseled concerning their student loan repayment obligations. D Not App licable (The campus does not participate in financial aid.)

If students do not receive counse ling regarding student loan repayment obligations, insert the section number in Qarentheses and explain:

VER. January 1, 20 18 ACICS INITIAL GRANT OR RENEWAL OF ACCREDITATION REPORT Page 18 of 18

CRITERIA

(d) Institut ions shall document that students are counse led co nce rning their student loan repayment obligations .

3-6-600 - ADMI SSIONS

3-6-60 1. Enrollment Prerequi sites. The thr eshold admission

QUESTIONS

FOR MASTER'S DEGREES ONLY

requirement to a master 's degree program is a baccalaurea te 4.56 degree.

Do all students enroll ed in master 's degree program s possess a bachelor ' s degree?

If admission to a professional program is granted without a bacca laureate degree, the burden is on the inst.itution to demonstrate and justify that the alternate admission requirement is accepted by a recognized licensing or specialized accrediting agency and is common practice among accredited institutions of higher education. In such cases, admiss ion may be granted only to eligible students who have comp leted, at a minimum, an associa te' s degree or equivalent.

If the insti tution chooses to award a suitable baccala ureate degree upon comp le6on of specified requirements or concurrently with the award of the professional master's degree , the baccalaureate degree cunicu lum must be approved by the Council.

3-6-602. Eval11atio11 of Applicants. Institutions should use appropriate techniques to evaluate applicants and to determine whether they have the academic qualifications to benefit from graduate study.

4.57

0Ye s 0No

If No, describe the alternate admiss ions requirement that is acceP.,!ed by a recognized licensing or specialized agency:

If there is no accepta nce by a recognized agency or evidence that this is common practice, insert the section number in parentheses , list student names, and explain:

Describe the techniques used by the institution to evaluate applicants' qualifications to benefit from graduate study.

Are these techniques appropriate? 0Ye s 0No

If No, insert the section number in parenthese s and ex lain:

GENERAL COMMENTS:

COMMENDATIONS:

RECOMMENDATIONS :

Case Name: In the Matter of Accrediting Council for Independent Colleges and Schools

Docket No.: 16-44-0

Filing Party: Respondent, Accrediting Council for Independent Colleges and Schools

Exhibit No.: B-0-159

December 16, 2016

VIA E-MAIL ONLY

Rev. Ronnie L. Williams President Camelot College 2618 Wooddale Boulevard , Suite A Baton Rouge , LA 70805

ID Code 0001131 l(MC)

home@came lotcollege .com

Subject: Appeal to Council of ACICS Staff PVP Review Decisions/Rejections

Dear Rev. Williams:

The Council has reviewed and considered the institution's appea l of the ACICS staff's decision to consider invalid the placements of Advanced Medical Assistant (AMA) graduates in phlebotomy , mental health tech, and certified nursing assistant positions; and Cosmetology graduates in Mary Kay positions , as placed by skills. While much of a curriculum argument was not provided for the Cosmeto logy program, according to the institution , " ... the above three discip lines are major tra ining components in our Advanced Medica l Ass istant program".

However , the Council's review of the AMA curriculum provided in the institution ' s request indicate that Phlebotomy is an 80-hour , 2 credit course ; Nurse Aid Training is an 80-hour , 4-credit course; and Me nt al Health Tech is another 80-hour , 4-credit course . Hence , these "disciplines" , independently , are not major training components of the AMA curriculum.

The Council also considered the institution 's argument that during its most recent renewal of accreditation vis it the ACICS review team accepted these placements as appropriate . While the Council' empathizes with the institution on the confusion that this may cause, it is important that the institution recognizes that the Council has purposefully strengthened and clarified in numerous webinars and memoranda to the field its heightened expectations on placements since that review cycle .

As a result of its thorough cons ideration of the institution ' s request, including the attestations from graduates and employers , the Council has determined that the staff's analysis and review are consistent with its expectations on the interpretation of the placement definit ion and the institution must submi t the following to the Council:

1. The placement documentation to support all graduates classified as placed on the 2016 Campus Accountab ility Report (CAR) along with documents to support those classified as not available for placement.

750 First Street, NE, Suite 980 e washington, DC 20002 - 4223 • t - 202.336.6780 • f - 202.842.2593 hww .acics.org

ACCREDITING COUNCIL FOR INDEPENDENT COLLEGES AND SCHOOLS

December 16, 2016 Rev. Williams Page 2 of 2

2. Revised publication and advertising materials, including the catalog, web site, and brochures , to accurately reflect the objectives of the Advanced Medical Assistant and Cosmetology programs , removing all references to careers in those areas identified as inappropriate - Mary Kay Consultant, Phlebotomy , Mental Health Tech , and Certified Nurse Assistant.

Further , the institution needs to address the serious disconnect between statements of concern for its students in the context of comparative high costs and length of training for enrollees in the AMA program being routed into low-level paying jobs for CNAs, by example, when shorter and cheaper options would have better served their interest relative to the outcome.

The requested information must be submitted to the Council's office via car@ac ics.org no later than February 28, 2017 . Failure to submit the information as requested may result in an adverse action against the institution. If you have any questions , please contact me at pwgilliam@acics.org.

Sincerely,

Perliter Walters-Gilliam Vice President - Accreditation

c: Mr. Roger J. Williams, Interim President (rjwilliams@acics.org) Dr. Terron King , Senior Manager, Institutional and Program Review (tking@acics .org)

From: To: Cc:

Subject: Date :

Perliter Walters - Gilliam

l(b)(6) paol com" Roger J wm;ams RE: PVP (Camelot College- 00011311)

Wednesday , October 19, 2016 3 :18:00 PM

Dear Pastor Williams: This is to follow up on our telephone call on Monday concerning your response to Mr. Williams , relative to the placement of CNAs and Mental Health Techs from the Advanced Medical Assistant (AMA) program . To ensure that we are clear, it is necessary that I reiterate ACICS' position. We do not consider these placements to be appropriate , and the campus has been invited to submit, for the Council 's consideration , documentation to support its position that these placements justify the $13 , 897.81 investment in the AMA program. However, the monthly PVP submissions will be validated from ACICS' position. Please email these materials Mr. William's attention and we will process them accordingly. Thank you.

Ms. Perliter Walters-Gilliam Associate Vice President - Accreditat ion Accrediting Council for Independent Colleges and Schools 750 First Street, NE I Suite 980 I Washington, DC 20002 www.acics.org I 202.336.6769 - p I 202.421.5935 - c

C ONFIDENTIALITY N OTICE:

This communicati on is only intended for the persons or entities to which it is addressed or copied and may contain information that is confidential and/or privileged in some way. Distribution or copying of this communication or the information contained herein is not expressly authorized. A C I CS reserves the right to disclose this communication as required by law without the consent of the persons or entities to which this communication is addressed.

From: " !(b)(6) l@aol.com" 4(b)(6l 1@aol.com> Date : Sunday, October 16, 2016 at 4:19 PM

To: Roger J Williams <riwilliams@acjcs.org> Subject: Fwd: PVP (Camelo t College-000 11311)

Mr. Roger Williams, Thank you for your guidance in your October 12, 2016, letter. I sincerely apologize for giving the perception that we were resisting the guidance of the organization [ACICS] that initially gave us the opportunity twenty-six years ago to help thousands of graduates to have successful career jobs. Please know that we would never resist the guidance of our Accrediting Commission and we are fully aware of the pending ACICS Petition for Re-recognition with the Department of Education. My letter to .... was only intended to inform our Commission that some of our graduates who were classified as CNA's are performing Medical Assistant tasks such as Computerized Patient Charting , Initial Patient Assessments , Vital Sign Checks and other Medical Assistant tasks also on their jobs

as we identified in our recent survey. We inadvertently classified them by Title Match in the PVP system instead of placing them by Skills Match. I am referring to the guidance we received in the Placement Verification Program Guidelines on ACICS website Respectfully, we know that students who graduated from a six week or short term CNA school could not perform the Medical Assistant skills that our graduates perform. Again, respectfully, this 1s the reason why The Baton Rouge General approached Camelot with the concept of adding more skill sets to the Medical Assistant program in an effort to hire more qualified health care professionals These skills can be validated by speaking with our graduates or their employers Also, I would love to have an opportunity to speak with you more on this issue and to speak with you on our outreach efforts to our Louisiana Congressional Delegation with regards to the pending decision by the Secretary of Education Please call me at 225-907-3310 or give a time that you could be available for me to call you. Again respectfully, Pastor Ronnie L Williams

From: To: Cc: subject: Date : Attac hmen ts:

Dear Mr. Copt,

PVP review

ccopt@hunterbuslnessschool.edu PVP review : Per1iter Walters-Gilliam ; Roger J Williams

RE: PVP Submission Concerns Thursday , ~bruary 16, 2017 4:45 : 18 PM

image001.png imageoo2 png

The PVP review committee as well as an additional sub ject specialist rev iewed the information that you submitted regarding the PVP submissions for the Medical Office Administration and Medical

Assistant programs. Upon review the committee has determined the following:

The Medical Office Administration placements are suitable placements based on the skills presented. Based on the curriculum reviewed, predominant skills from the program are utilized in the posit ions. However, please be advised that the ques t ion of the appropriateness of the CIP code remains and will be addressed in the renewal of accreditation review at the Council's April meet ing.

For the phlebotomy placement of the medical assistant graduates, the committee affirms the staff

decision regarding the phlebotomy placements as invalid. Although graduates in such placements may be using some skills from various courses, the assessment is that the placement does not require

the use of predominant skills from the program as a whole. Secondly, while employers may prefer graduates of a medical assis t ing program due to the additional skills they attain , these addit ional

skills, for which the graduate invested extra resources to obtain, may be utilized in positions that more closely align with the training received.

Regards,

i<b)(6)

Manager, Institutional Compliance Accrediting Council for Independent Colleges and Schools

From: Perliter Walters-Gilliam Sent: Thursday, January 26, 2017 9:25 AM To: chuck copt Cc: Karly Zeigler; Corrisa Barker; Roger J Williams Subject: RE: PVP Submission Concerns

Good mornin g Mr. Copt Thank you f or your detailed response. The PVP Review Team will meet to discuss and I will follow up at my earliest opportunity .

Ms. Perliter Walt ers-Gilliam Vice President - Accreditation Accrediting Council for Independent Colleges and Schools

750 First Street, NE I Suite 980 I Washington , DC 20002 www .ac ics.org I 202.336.6769 - p I

C oNFIDENT TALITY N oTTcE:

This communication is only intended for the persons or ent ities to which it is addressed or copied and may

contain information that is confidential and/or privileged in some way. Distribution or copying of this communication or the information contained herein is not express ly authorized. ACICS reserves the right to disclose this communication as required by law without the consent of the persons or entities to which this communication is addressed.

From : chuck copt [mailto:ccopt@hunterbusinessschool.edu] Sent: Wednesday, January 25, 2017 5:21 PM To: Perliter Walters-Gilliam Subject: FW: PVP Submission Concerns

Dear Ms. Walters-Gilliam :

As indicated in my previous email, I receive d the letter that you submitted to ~ n January 13, 2017 concern ing the "PVP" criter ia. Your response left our management team with several questions and concerns that we would like to address.

Genera l Office Placement for Graduates from the Medical Office Administration program:

In your response you indicate that we should change the program description in our catalog , on our webs ite, and any other publication to no longer make reference to the "business environment". If we remove the wording "business environment" from the program description found in our catalog and published on our webs ite and replace it with the wording "genera l office skills", will this then meet the criteria that ACICS uses thereby allowing our institution to place students in a "general office" setting outside of the health care field providing the sh1dent is utilizing a predominant number of skills that were acquired in the courses that focus on "general office" ski lls? Please advise.

Placements Pertaining to Phlebotomy:

We were initially wai ting for a lette r from LabCorp which is a nationa l laboratory testing company. The letter was to support the need for trained Medical Assistants from Hunter as a requirement to work as a phlebotom ist. We have been waiting for the Regional Field Superv isor to forward the letter to their Corporate Human Resources department for approval before sending it on to Hunter Business Schoo l. We decided to submit the fo llowing supportive infonnation and then forward the letter from Regional Superv isor, LabCorp in a separate ema il.

As you point out , there must be predominant use of skills from the program in the position to make it a valid placement, however in your letter you consider Phlebotomy one skill learned as part of the larger set of skills obtained from the program . Our students are only placed as phlebotomists at two Nat ional Laboratories who typically only hire employees with more than l year of work experience . In their job postings LabCorp advertises for PST Patient Services Technician (see attached posting) and Quest Diagnostics uses the title Phlebotom y Services Rep I (see attached posting) . We used the job title ph lebotomist as an easy way to identify the type of work the shldents do. Wou ld it help ifwe change the titles that we have been using for these two organizations to match the title in the job postings? Both LabCorp and Quest Diagnostic s make an exceptio n for our students because of their education and training at our instihltion, in which our Medical Assistant program has programmatic accreditation by the Commission on Accreditation of Allied Health Education Programs since 20 13 (/etterfrom LabCorp to follow in a separate email) .

In your letter you stated that phlebotomy is covered in two courses along with Laboratory Procedur es (120) hours. This is 120 hours in a 910-hour program which represents 13% of the program. It is our assertion that the phlebotom y placement s that we state as placeme nts are skills-based and utilize 73% of the total curriculum. If you look at the job description found below from Quest Diagnostics , 667 hours out of the 910 hours offered in our Medical Assistant program are achlally utilized within the job description . They

require students to utili/c skills that ha,c been taught" ithin the folio" ing courses

\1A 101 A Ascps1s & Assisting ,nth Minor Surgery (27) hrs \1A 102 Commu111cation & Human Relations ((l0) hrs \1A201 Lnnal)sis & \11crobiolog) (W) hrs \1A202 Keyboarding" ith M1crosol't Word ((i0) hrs \1A301 Phlebotom) & Laborator;, Procedures I (W) hrs \1A401 Phlebotomy & Laboralor;,· Procedures II ((i0) hrs \1A:i01 Clinical skills (W) hrs \1A)02 \1cd1cal Admi111strati,c & Business Practices (W) hrs \1A(i02 Computcn/cd Medical Hillmg & E\1R (W) hrs \1A801 f'\:tcrnsh1p ( 1 (i0) hrs

Helo\\· is the job description fi-om Quest Laboratories that \\"C \ c used in dctcrn1ining that our placements meet the skills-based requirements set forth b) ACICS. "hich 1s: ··An) graduate or completer of a program that \\"as placed based upon the required use of skills learned lll the studcnl·s program as a predominant component of the job. These skills must be those listed in the institution· s published program description and a maJoril) of these skills must be documented in the cmploycr·sjob description as required or desired skills. duties or rcsponsibil1tics··

Quest Diagnostics Joh Description Job Title: I

Phlcbotom~ Sen ices I Job Family: I Laborator:, Rep I

Rcporh To: I Field Operations Manager I Grade

Ba~ic Purpo~c: Under the direction of the area supcn·isor. perform dad) acti,·itics of the Patient Scn·icc Center /Mob1le/In­oflicc Phlebotomy accurately and on time. \1amlam a sale and prolCss1onal cn,·ironmcnl. Performs" ith confidence. both the forensic and cl1111cal specimen collection and processing duties follmnng established practices and procedures. Maintains required records and documentation. Demonstrates organ1n1lional commitment and promotes a pos1ti,-c image lo patients. clients. cmplo) ccs and the public in general.

Dutic~ and Rc~pon~ibilitics: 1 Greet customers appropriately Treat all customers in a courteous manner 2 Ensures all field phlcbotom) and PSC specimens arc collected accurate!) and on time. a. Collects specimens accordmg to established procedures. b. Responsible for completing requisitions accurately c. Call clients to confirm hand,,rillcn orders., cril~ tcst(s) ordered. obtam accurate billing mfonnat10n. 1 c D1agnos1s codes. UPIN mfonnat10n. etc. d. Research tcst/cl1cnt rnformation utilu.rng lab computers~ stem or Director:, of Sen 1cc c. Label. centrifuge. split. and frcc/C spccuncns as required b~ test order. f Package spccuncns for transport g. Adnlllustcrs glucose. lactose and d-:x~ lose oral solutions according to established trauung. 3 \1amtams required records and documcntat10n. a. Reads. understands and complies \\!th departmental polic1cs. protocols and procedures (1.c Procedure Manuals. Safct~ Manual. Compliance \1anual. Automobile policies and procedures. [mplo~ cc Handbook Qualit~ Assurance \1anual). b. Mamtams all appropnatc PSC/Phlcbotom~ logs c. Assist,, ith compilation of month!~ statistics and data Submits data on time monthh d. Pcrfonn basic clcncal duties. 1.c J"ilmg. fa:xmg. prcpanng mail. Will be required to perform electronic data cntr,, c. Submits accurate tune and tra, cl logs as directed b~ management and on tllnc. f Submits accurate C.\.pcnsc forms. if applicable. on the required da~ 4 Demonstrates organuational commitment

a. Adheres lo departmental and company code or groom mg and dress code and lab coat policies. appearing neat and clean al all times. b. Reports on time lo,, ork. fol lo" ing allcndancc guidelines. c. Ans"crs the telephone in a rncndly and helpful manner. by mcorpornting the company name. sclr­idcntiricalion and a hclprul statement d. Communicates appropnatcl) "ith clients. patients. co" orkcrs and the general public. c. Communicates all unrcsoh-cd problems immcd1atcl) to the appropnalc \1anagcr. Supcn·isor. Group Leader or PSR II for resolution Rem ams polite and courteous at all llmc. :'i Miscellaneous duties and responsibilities.

a. Keeps "ork area neat and clean. Disposes orb1oha/ard containers \\·hen scheduled. b. I !clp ,nth irn en tones and other tasks as assigned. c. Stock supplies as needed. d. Pcrfonn s other department-related cl enc al duties "hen assigned. c. Ans"crs phone and dispatch calls "hen assigned. r. Participates on teams and special projects "hen asked.

Qualification~: [ducat10n Preferred: BS ,,ith DMLT/B Sc (MLT) \Vork 1-:'l:pcncncc: 1 year phlebotomy cxpcncncc.

Customer sen 1cc in a sen 1cc c1n ironmcnt. Other·

Must be flexible and a, mlable based on staffing requirements. holida, s. on call and o, crtime Excellent phlcbotom~ slills to mclude pcd1atnc and gcnatnc

"eekcnds.

Demonstrates good organu.ation. commun1cat10n. and mtcrpcrsonal slills. 1s able to manage concerns of patients and emplo~ ees 1n a profc:ss10nal manner Capable of handling multiple priorities Ill a ]ugh, olume selling Abilit~ to perform data-entr:,

Additionally. "c encourage our students lo ccrtir) thcmschcs through the American \1cd1cal Technologists as a Registered \1cd1cal Assistant \Yh1ch is one or the lcadmg ccr11rying organinitions ror \1cd1cal Assistants. This exam. encompasses Medical Assisting. EKG Tcch111c1an and Phlcbotomisl. Ir they \Yant to be ccrtiricd only lll Phlebotomy (especially al'tcr obtammg a Job offer from Quest). bclm, 1s the content or the American Medical Technologists Phlcbotom) 1-:'l:am.

AVIT Regi~tered Phlebotom~· Technician (RPT) Certification E'\amination Construction Parameter~ '\umber or items 111 catcgor:,·

Category. Sub-catcgor;,. and Compclcnc)

I. Obtaining Blood Samples (-11.5% o/'le.11) A. ldcntir) correct patient properly H. Select appropriate containers for specimens and knmy requirements ror container idcntiricat1on C. Knmy physiological aspects or blood collection D. Prepare patient ror ,·anous tests J-:. Select proper, c111punclurc site F Pcrfonn ,-c111punclurcs G Collect specimen in proper tubc-dra\\" sequence H Perform skm punctures I Perform heel punctures on mfants J. PrO\ 1dc proper post care of , cnous. arterial. & skm puncture sites K Handle blood samples to marntarn spccuncn mtegrit~

L. Label transfusion scn·iccs (blood bank) specimens according lo proper Protocol 1/unter'.I Coune.\' in which above i.I learned:

a. MA:30/ Phleboton~v and l.aboratory Procedure.\ I (60 hn) b. MA:.JO/ Phleboton~v and l.aboratory Procedure.\ II (MJ hn) c. MA:HOI Extern.\hip (/60 hn)

11. Specimen Collection and Proces~ing (I 5 5% (!{!es/) A. Proper!) handle non-blood specimens to mamlmn their mlcgrity H. Proper!) collect and handle specimens ,nth time/temperature requirements C. Proper!) collect and handle specimens for blood cultures D. Select proper station for specimen dcln CJ;,

E. Process specimens for shippmg F Instruct patient 111 the collection ofunnc specimens G Instruct patient in the collection ol'othcr specimens I! Collect and process pomt-ol'-carc testing (POCT) specimens 1/unter'.I coune.\' in which the above i.I learned

a. MA:20/ l!rina(v.\i.\ and Microbiology (MJ hn) b. MA:30/ Phleboton~v and l.aboratory Procedure.\ I (60 hn) c. MA:.JO/ Phleboton~v and l.aboratory Procedure.\ II (MJ hn) d. MA:HOI Extern.\hip (/60 hn)

111. Time Management and As~ignment Organi,.ation (H 0% (!{!es/) A. Read ph) sician orders and rcqu1s1tions H. Set priorities for specimen collection C. Schedule llmc intcn als for tolerance tests D. Schedule time mtcn·als l'or drug-dependent tests E. Refer problems to supcn 1sor appropriately F Cooperate,, ith co-\\orkcrs lll the completion of assignments 1/unter'.I Coune.\' in which the above i.I learned

a. MA:502 Medical Admini.Itrative and Uu.\ine.u Practice.\' (MJ hn) b. MA: 1()2 Communication and 1/uman Relation.\ (60 hn) c. MA:!()/ U Pharmacology _(33 hn) d. MA:HOI Extern.\hip (/60 hn)

IV. Profc~sional Communication~ (-1.5% o/'le.11) A. De, clop and use proper and prolCss1onal communication skills" 1th staff patients. and families H. Use proper lcch111quc and ctiqucllc f'or ans\Ycnng the telephone C. lnl'orn1 patients of special test requirements 1/unter'.I coune.\' in which the above i.I learned

a. MA: 1()2 Communication and 1/uman Relation.\ (60 hn) b. MA:HOI Extern.\hip (/60 hn)

V. Clerical Skill~ and Du tie~ (5 5% (!{!es/) A. Chart or l'ile labornto1;,-gcncratcd reports proper!) H. Enter. rctric,-c. and ,-cnf) patient collection data and special notations usmg appropriate sources C. Maintain i!l\-cnto1;, lc,-cls. order and restock supplies D. Emplo) computer skills 1/unter'.I coune.\' in which the above i.I learned

a. MA:202 Keyboarding with Micrmoft Word (MJ hn) b. MA:602 Computerized nilling c. MA. 1()2 Communirntion and Human Relation.\' (MJ hn) d. MA:HOI Extern.\hip (/60 hn)

VI. Safety Standards and Procedures (10.0% of test) A. Identify appropriat e regulatory and standard-se tting agencies B. Know the use of material safety data sheets C. Employ Universal/Standard precautions D. Employ infection control and isolation teclmiques E. Recognize patient problems related to syncope , nausea, and other complications Hunter's courses in which the above is learned

a. MA:102 Communication and Human Relations (60 hrs) b. MA:101A Asepsis (27 hrs) c. MA:301 Phlebotomy and Laboratory Procedures I (60 hrs) d. MA:401 Phlebotomy and Laboratory Procedures II (60 hrs) e. MA:801 Externship (160 hrs)

VII. Legal, Ethical, and Professional Considerations (6.0% of test) A. Know principles of liability regarding the practice of phlebotomy B. Perform duties professionally, ethically, and legally, adhering to crimina l justic e and civi l rights acts C. Employ professional conduct and appearance in the performance of duties Hunter' s courses in which the above is learned

a. MA:102 Communication and Human Relations (60 hrs) b. MA:801 Externship (160hrs)

VIII. Terminology, Anatomy, and Physiology (9.0% of test) A. Employ basic terminolo gy including suffixes , prefixes, and root words B. Know basic anatomy C. Know basic physiological systems Hunter's courses in which the above are learned

a. MA:302 A&P I with Medical Terminology (60 hrs) b. MA:402 A&P II with Medical Terminology (60 hrs) c. MA:801 Externs hip (160 hrs)

As yo u can see, even if you do not include the externship, our students must learn 65. 9% of the total Medical Assistant Program in order to pass the AMT Phlebotomy Exam.

We are looking to reso lve these issues as quickly as possible so that we may continue to support our students in finding them employment that meets their career aspirations and the cri teria set forth by ACICS. Thank you in advance for you time, we look forward to your response.

Sincerely,

l(b)(6)

Chuck Copt

Director of Education & Evening School Director

~~ HUNTUJ Hunter Business School

Brookhaven Executive Center

3247 Route 112 Bldg. 3

Medfo rd, NY 11763 (631) 736-7360 Ext. .,,..fb,.,.,,)(6.,....) --,

www.hun t erbus inessschool.edu

From: To :

Cc: Subject: Date : Attac hmen ts :

Perliter Walters-Gilliam

Ms. Tibby Lovema n

Roger J Will iams ; PVP review

FW: PVP Submission Concerns

Tuesday, February 07, 2017 1:44 :00 PM

PST Specialist · Rushing Queens • NY at LABORATORY CORP OF AMERICA HOLDINGS.pdf

ouest phlebotomy Job descr1pt1on pdf RPT Content Outl ine detai l.pdf image002 .png 1mageoo3,png

Campus response below ...

From: chuck copt [ mailto:ccopt@hunte rbusinessschool.edu] Sent: Wednesday, January 25, 2017 5:21 PM To: Perliter Walters -Gilliam Subject: FW: PVP Submission Concerns

Dear Ms. Walters-Gilliam :

As indicated in my previous emai l, I rece ived the letter that you submitted to - on January 13, 2017 concerning the "PVP" criteria. Your response left our management team with several questions and concerns that we would like to address.

General Office Placement for Graduates from the Medical Office Administration 1>rogram:

In your response you indicate that we should change the program description in our catalog, on our website, and any other publication to no longer make reference to the "business environment" . If we remove the wording "business environment" from the program description found in our catalog and publi shed on our website and replace it with the wording "general office skills", will this then meet the criteria that ACICS uses thereby allowing our institution to place students in a "general office" setting outside of the health care field providing the student is utilizing a predomin ant number of skills that were acquired in the courses that focus on "general office" skills? Please advise.

Placements Perta ining to Phleboto my:

We were initially wa iting for a letter from LabCorp which is a national laboratory testing company. The letter was to support the need for trained Medical Assistants from Hw1ter as a requirement to work as a phlebotomist. We have been wai ting for the Regional Field Supervisor to forward the letter to their Corporate Human Resources departm ent for approva l before sending it on to Hunter Business School. We decided to submit the following supportive inforniation and then forward the letter from -

- Regional Superv isor, Lab Corp in a separate email.

As you point out, there must be predominant use of skills from the program in the pos ition to make it a valid placement, howeve r in your letter you consider Phlebotomy one skill learned as part of the larger set of skills obtained from the program . Our students are only placed as phlebotomists at two National Laboratories who typically only hire employees with more than I yea r of work experience. In their job postings LabCorp advertises for PST Patient Services Technician (see attached posting) and Quest Diagnostics uses the title Phlebotomy Services Rep I (see attached posting} . We used the job title phlebotomist as an easy way to identify the type of work the students do. Would it help if we change the titles that we have been using for these two organizations to match the title in the job postings? Both LabCorp and Quest Diagnostics make an except ion fo r our students because of their education and training at our institution, in which our Medical Assistant program has programm atic accreditation by the Commission on Accreditation of Allied Health Education Programs since 20 13 (letter from LabCorp to follow in a separate email) .

In your letter you stated that phlebotomy is covered in two courses along with Laboratory Procedures

( 120) hours. This is 120 hours 111 a ()10-hour program \Yhich represents 13(% of the program It is our assertion that the phlebotomy placements that \\C state as placements arc skills-based and utili/c 7311/iJ or the total curriculum Ir)oU look al the Job description found bclmY f'rom Quest Diagnostics. (i(i7 hours out of the())() hours offered 111 our \1cd1cal Assistant program arc actual I) utili/cd \\ ith111 the job description They require students to utili/c skills that ha,c been taught ,nthin the IOllmnng courses

\1A101A Ascpsis & Ass1st111g ,nth Minor Surgery (27) hrs \1A 102 Communication & I !uman Relations (W) hrs \1A201 Lnnal)sis & Microbiology (W) hrs \1A202 Kc) boarding\\ ith Microsol't \Vord ((i0) hrs \1A301 Phlcbotom) & Laboratory Procedures I (W) hrs \1A401 Phlcbotom) & Laborato1;, Procedures II ((i0) hrs \1A:i01 Clmical skills ((i0) hrs \1A)02 \1cd1cal Adm1111slrati,-c & Hus111css Practices ((i0) hrs \1A(i02 Computcri/cd \1cd1cal Hill111g & E\1R ((i0) hrs \1A801 E'Xlcrnsh1p (l(i0) hrs

Helmy 1s the Job description from Quest Laboratories that\\ c · \"C used 111 dctcrmin111g that our placements meet the skills-based requirements sci forth b) ACICS. \\hich 1s: ··Any graduate or completer or a program that \\"as placed based upon the required use of skills learned 111 the studcnl·s program as a prcdom111anl component or the job. These skills must be those listed 111 the institution· s published program description and a maJoril) of these skills must be documented lll the cmplo) er· s job description as required or desired skills. duties or rcsponsibil1tics··

Quest Diagnostics Job Description Joh Title: Rcporh To:

Ba~ic Purpose:

I Phlebotom~ Sen ices I Job Family: I Laborntor:, Rep I

I Field Operations \1anagcr I Grade

Under the direction of the area supcn 1sor. pcrfonn dail) acti,·itics or the Patient Scn·icc Center /Mob1lc/ln-oflicc Phlcbotom) accurate!) and on time. \1ainta111 a salC and prolCss1onal cn,·ironmcnl. PcrlOrn1s \Yith confidence. both the rorcns1c and cl1111cal specimen collection and proccssmg duties fol Im, ing established practices and procedures. \1a111la111s required records and documentation Demonstrates orga111n1lional commitment and promotes a positi,-c image to patients. clients. cmplo)CCS and the public 111 general

Duties and Responsibilities: I Greet customers appropnatcl~ Treat all customers ma courteous manner 2 Ensures all field phlebotom~ and PSC spcc11ncns arc collected accurate!~ and on time a. Collects spccuncns accordmg to established procedures. b. Responsible for completing rcqu1sitions accurate!~ c. Call clients to confirm hand,uittcn orders. ,cnf~ tcst(s) ordered. obtam accurate billmg mfonnation. 1.c D1agnos1s codes. LP!:\ mformation. etc d. Research tcst/cl1cnt mfonnat10n utili/.lllg lab computers~ stem or Director:, of Sen 1cc. c. Label. ccntnfugc. split. and frcc/.C spcrnncns as required b~ test order. f Package spccuncns for transport. g. Admrn1stcrs glucose. lactose and d-:x~ lose oral solutions according to established trarnmg. 3 \1amtains required records and documentation a. Reads. understands and complies \\ 1th departmental policies. protocols and procedures (i c Procedure Manuals. Safot~ \1anual. Compliance Manual. Automobile policies and procedures. [mplo~ cc Handbook. Qualit~ Assurance \1anual) b. \1amtams all appropriate PSC/Phlebotom~ logs c. Assist \\ ith compilation of month!~ statistics and data. Submits data on lane monthh

d. Pcrf'orn1 basic clerical duties. i.e. f'ilmg. faxmg. preparing mail Will be required to pcrlOm1 clectromc data entry c. Submits accurate time and trn,·cl logs as directed by management and on time. r. Submits accurate C'l:pcnsc IOrn1s. if' applicable. on the required da) . ..i. Demonstrates organinilional commitment. a. Adheres lo departmental and company code of' grooming and dress code and lab coal policies. appearing neat and clean at all times 6. Reports on time to "·ork. f'ollmnng attendance guidelines c. Ans"-crs the telephone lll a f'ricndly and hclpf'ul manner. by incorporating the compan) name. sclf'­idcntif'icalion and a hclpf'ul statement d. Commumcalcs appropnalcl) "·ith clients. patients. cmnirkcrs and the general public. c. Communicates all unrcsoh-cd problems 1mmcdiatcl) lo the appropnalc Manager. Supcn·isor. Group Leader or PSR II IOr resolution. Remains polite and courteous at all time. :'i M1sccllancous duties and responsibilities.

a. Keeps "ork area neat and clean. Disposes of' b1ohanird conlamcrs "·hen scheduled. b. I kip ,nth im en tones and other tasks as assigned. c. Stock supplies as needed. d. PcrlOrn1s other department-related clerical duties "hen assigned. c. Ans"-crs phone and dispatch calls "hen assigned. r. Participates on teams and special projects "·hen asked.

Qualification~-.. [ducat10n Prefr:rred· BS ,,1th D\1LT/B.Sc (\1LT) Work Experience. 1 year phlebotom) experience.

Customer scn·icc 111 a sen ice c1n-ironmcnl. Other:

Must be 11cxiblc and a, ailablc based on staffing requirements. holida, s. on call and o, ertimc Excellent phlcbotom~ sl1lls to mcludc pcd1atnc and gcnatnc

"eelends.

Demonstrates good organ1 ✓at10n. commun1cat10n. and mterpersonal slills. able to manage concerns of patients and cmplo~ ces 1n a profr:ss10nal manner. Capable of handling multiple pnorit1cs Ill a high ,olumc setting Abil11' to perform data-en!~

,s

Additional!). \\"C encourage our students lo cert if') them sch cs through the Am enc an Medical Tcchnolog1sts as a Registered Medical Assistant "hich 1s one of' the lead mg cert if') mg orga111n1lions for \1cd1cal Assistants. This exam. encompasses Medical Assisting. EKG Tcch111c1an and Phlebotom1sl. If' they" ant to be ccrtilicd only 111 Phlebotomy (especially af'tcr obtaining a job offer f'rom Quest). bclmY 1s the content of' the American \1cd1cal Tcchnolog1sls Phlebotomy Exam

AVIT Regi~tered Phlcbotom~· Technician (RPT) Certification E"amination Construction Parameter~ '\umber of' items in catcgo~

Category. Sub-category. and Competency

I. Obtaining Blood Sample~ (.JI J% o(le.11)

A Idcnt1f'y correct patient properly H. Select appropnalc containers f'or specimens and knmy requirements f'or container idcntilication C. Knmy physiological aspects of' blood collection D. Prepare patient for ,·arious tests J-:. Select proper ,-cnipuncturc site

F Pcrfonn ,cnipunclurcs G Collect specimen in proper tubc-dnm sequence I! Perform skin punctures I. Pcrfonn heel punctures on infants J. Prm·idc proper post care of ,-cnous. arlcnal. & skm puncture sites K I !andlc blood samples to mamlam specimen intcgnl) L. Label lransfllsion sen ices (blood bank) specimens according lo proper Protocol 1/unter'.I Coune.\ in which ahove i.\ learned:

a. MA:30/ Phleboton~r and Laboratory Procedure.\ I (60 hn) b. MA:.JO/ Phleboton~r and Laboratory Procedure.\ II (60 hn) c. MA:8(J/ Extern.\hip (IMJ hn)

11. Specimen Collection and Proccs~ing (I 5 5% o( le.11) A Properly handle non-blood specimens to mamlmn their mlcgrity H. Proper!) collect and handle specimens" ith time/temperature requirements C. Proper!) collect and handle specimens for blood cultures D. Select proper station for specimen dclnuy E. Process specimens for shippmg F Instruct patient lll the collection of unnc specimens G Instruct patient lll the collection of other specimens I! Collect and process point-of-care testing (POCT) specimens 1/unter'.I coune.\' in which the above i.I learned

a. MA:20/ Urina(r.Ii.I and Microhiology (60 hn) b. MA:30/ Phleboton~r and Laboratory Procedure.\ I (60 hn) c. MA:.J(J/ Phlehotomy and Lahoratory Procedure.\' II (MJ hn) d. MA:HOI Ex.term-hip (/60 hn)

Ill. Time Vlanagcmcnt and As~ignmcnt Organi,.ation (8.()% (!{!es/) A Read ph) sician orders and requisitions H. Set priorities for specimen collection C. Schedule llmc intcn als for tolerance tests D. Schedule time mlcn·als for drug-dependent tests E. Rcfor problems to supcn isor appropriately F Cooperate" ith co-" orkcrs in the completion of assignments 1/unter'.I Coune.\ in which the ahove i.\ learned

a. MA:502 Medieal Admini.Itrative and Uu.\ine.u Practice.\ (60 hn) b. MA: /02 Communirntion and 1/uman Relation.\' (60 hn) c. MA:l(J/UPharmacology_(33hn) d. MA:HOI Ex.term-hip (/60 hn)

IV. Profc~~ional Communication~ (-J 5% o(le.11) A Dc,clop and use proper and professional commumcation skills "ith staff patients. and families H. Use proper technique and ctiqucllc for ans,vcnng the telephone C. lnlOm1 patients of special test requirements 1/unter'.I coune.\' in which the above i.I learned

a. MA: 1()2 Communirntion and 1/uman Relation.\' (60 hn) b. MA:HOI Ex.term-hip (/60 hn)

V. Clerical Skill~ and Du tic~ (5 5% o( le.11) A Chart or lile laboralory-gcncralcd reports proper!) H. Enter. rctnc, c. and , cnfy patient collection data and special notations usmg appropriate sources C. Maintain irncnlory le,els. order and restock supplies D. Employ computer skills

Hunter's courses in which the above is learned a. MA:202 Keyboarding with Microsoft Word (60 hrs) b. MA:602 Computerized Billing c. MA:102 Communication and Human Relations (60 hrs) d. MA:801 Externship (160 hrs)

VI. Safety Standards and Procedures (10.0% of test) A. Identify appropriate regulatory and standard-setting agencies B. Know the use of material safety data sheets C. Employ Universal/Standard precautions D. Employ infection control and isolation techn iques E. Recognize patient problems related to syncope, nausea, and other complications Hunter's courses in which the above is learned

a. MA:102 Communication and Human Relations (60 hrs) b. MA:J0JA Asepsis (27 hrs) c. MA:301 Phlebotomy and Laboratory Procedures I (60 hrs) d. MA:401 Phlebotomy and Laboratory Procedures II (60 hrs) e. MA:801 Externship (160 hrs)

VII. Legal , Ethical, and Professiona l Considerations (6.0% of test) A. Know principles of liabili ty regarding the practice of phlebotomy B. Perform duties professionally, ethically, and legally, adhering to crimina l just ice and civil rights acts C. Employ professional conduct and appearance in the performance of duties Hunter's courses in which the above is learned

a. MA:102 Communication and Human Relations (60 hrs) b. MA:801 Externship (160hrs)

VIII. Terminology, Anatomy, and Ph ysiology (9.0% of test) A. Employ basic terminology including suffixes, prefixes , and root words B. Know basic anatomy C. Know basic physiological systems Hunter's courses in which the above are learned

a. MA:302 A&P I with Medical Terminology (60 hrs) b. MA:402 A&P II with Medical Terminology (60 hrs) c. MA:801 Externship (160 hrs)

As you can see, even if you do not include the extemship , our students must learn 65 .9% of the total Medical Assistant Program in order to pass the AMT Phlebotomy Exam.

We are looking to resolve these issues as quickly as possible so that we may continue to support our students in finding them employment that meets their career aspirations and the criteria set forth by ACICS . Thank you in advance for you time, we look forward to your response.

Sincere ly, l(b)(6)

Chuck Copt

Director of Education & Evening School Director

~~ HUN~

Hunter Business School

Brookhaven Executive Center

3247 Route 112 Bldg. 3

Medford, NY 11763

(631) 736-7360 Ext. l(b)(6) I www.hunterbus inessschool.edu

From: To: Cc: Subject: Date: Importan ce :

Dear Ms. Nyx:

Perliter Walters-Gill iam

•invx@huotecbusioef45Chool edu• Booer J Williams; LaTova Bovd; Kaclv Zeiala:; Coaisa Barker P\IP Submission u, ncems Friday, January 13, 2017 9:55:00 AM High

Latoya shared your email below for my review and follow up concerning placements deemed invalid for Medical Assistants grad uates in Phlebotomists positions. Consistent with guidance previously provided, this is considered to be invalid and all previously accepted submiss ions will be revised. The rationale is as follows: Phelobotomy is one skill learned as part of the larger set of skills obta ined from the program. Per our requirement, there must be predominant use if skills from the program in the position to make it a valid placement. Accord ing to the program outline on page 14 of the 2016/2 017 catalog , Phlebotomy is covered in two courses along with Laboratory Proced ures (120 hours) . This is 120 hours in a 910-hour program (13%).

I have also reviewed the general office placements for grad uates from the Medical Office Administration program. While a predominant number of courses in the program (11/16 = 68.75%) a is focused on general office, thereby justifying these classifications, the reference to "business environments" in the position description is inappropriate given that the CIP code

description of the Medical Office Administration (51.0710) reads as follows:

A program that prepares individuals , under the supervision of office managers and other professionals, to perform routine administrative dutie s ••••••••••••••••••••••••••• . Includes instruction in general office skills, data processing, office equipment operation , principles of medical record-keeping and business regulations , medical/clinical office procedures , and communications skills. A program that prepares individuals , under the supervision of office managers and other profe ssionals, to perform routine administrative duties in a medical, clinical , or health care facility/system office environment. Includes instruction in general office skills, data processing , office equipment operation , principles of medical record-keeping and business regulations , medical/clinical office procedures , and communications skills. (https-//nces ed ~ov/jpeds/cjpco<le/cjpdetail aspx?v=SS&cjp=S J 07 JO)

Hence, the Instituti on Is advised that the program description, in Its catalog , web s ite, and any other publication must be revised to no longer make reference to the business environment, or It should revise the program description along with the CIP Code designation accordingly. I note that the institution recently host ed the onsit e evaluation team which had serious concerns in this regard, with serious resistanc e by the campus. Hence, the institution is advised that it may respond to this assessm ent as part of its response to the Council's deferred Renewal of Accreditation action for the Council's consid eration at its April 2017 meeting.

Please advise if the changes will be made or if the instit ution will respond to Council in appeal.

Ms. Perllte r Walter s-GIiiiam Vice President - Accreditation Accred iting Counc il for Independent Colleges and Schools 750 First Street , NE I Suite 980 Washington , DC 20002

www acjcs orfl 1 202.336.6769 - p

C ONFIDENTIALITY N OTICE:

This communication is only intended for the persons or entities to which it is addr essed or cop ied and may contain information that is confidential and/or privileged in some way. Distribution or copying of this communicat ion or the information contained herein is no t expres sly authorized. AC ICS rese rves the right to disclose this commun ication as required by law wit hout the consent of the persons or entit ies to which thi s communicat ion is addressed .

From: Jenn ifer Nyx <jnvx@hunterbusjnessschool edu> Sent: Thursday , January 12, 2017 4:26:59 PM

To: LaToya Boyd

Subject : RE: Hello LaToya

Hello La.TolJa~

I do have a few questions. As you can see below , we have a few placem en ts that are stated as invalid. 4 of them are phlebotomists - which is not an accepted title bu t the skill sets are in alignm ent with the placement. ACICS is stating that it is invalid. In the past , when I have submitted Phlebotomists as pla cemen ts, it has been accepted, except for these last 4 from this past month.

Tue other plac ement , is a Medical Office Administration graduate. Her skill set is also in

alignment with the pla ceme nt. Pleas e see listed on our website: The Medical Office Administration program prepares students with the skills necessary to provide excellent administrative support while working and playing a key role in running an efficient , productive office in a variety of medical and business environments.

http · // wwwJmnterhusinessschool ed.n / programs lloug - islaud - wedica.l-office-administmtion -progr,un I

We have had a few Medical Offi ce Administration graduates who take jobs in a business environment , like -Please let me know what the next ste~ are to get this rectifi ed. Tuank you. ©

t- C O , s..,,'=--

1U

-lltl

Director Of Career Services

Hunter Business School

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www hunterbusinemchool edu 3247 Route 112, Building 3

Medford , NY 11763

631 -569- 7707 · Tel 631- 736-7310 - Fax

From : LaToya Boyd [mailto: L8oyd@acics.org ) Sent : Thursday, January 12, 2017 8:05 AM To: Jennifer Nyx Subject: RE: Hello LaToya

Hello Jenn ifer and Happy New Year to you too!

What ty pe of ques t ion do you have? Is it an IT quest ion or is it abou t your placement verificat ion?

Regards.

LaToya Boyd. MNML Accreditation Coordinator Accrediting Council for Independent Colleges and Schools 750 First Street. NE I Suite 980 I Washington. DC 20002 www ac;cs org 1 202.336.6777 - p

From : Jennifer Nyx [mailto·inyx@hunterbusjnessschool edul Sent : Wednesday, January 11, 2017 6:57 PM To: LaToya Boyd Subject: Hello LaToya

Hello La Toga~

Happq New Year! I was hoping that qou could steer me in th e r~t direc tion. Who would I contact a.bout the PVP as I have a few questions.

Thank qou. ©

Direc tor Of Career Services

Hunter Business School www hunterbusinessschool edu 3247 Route 112, Building 3

Medford , NY 11763 631 -569-77 07 • Tel

63 1-736 -7310 - Fax